Montana Holdings v. Doe [1]

Montana Holdings, a resort developer located in the Bahamas, filed a John Doe lawsuit in Arizona state court against the anonymous operator of the website www.resortbuyerbeware.com [2]. The website allegedly contained false and defamatory statements about a Montana Holdings resort project and the people involved in developing it. After filing suit, Montana Holdings subpoenaed the website's domain registrar, Domains By Proxy, Inc., and its web hosting service, GoDaddy.com, Inc., both Arizona corporations. The subpoenas sought identifying information for the website operator and other information about the website.

Doe appeared in the action and moved to dismiss the complaint and to quash the subpoenas. The Arizona court granted both of Doe's motions, holding that it did not have personal jurisdiction over him/her. The court reasoned that, even though Domains By Proxy and GoDaddy.com were Arizona corporations, the website operator's commercial relationships with them were not sufficient to create the minimum contacts necessary for personal jurisdiction over Doe, who was not an Arizona resident.